LEGAL
Privacy Policy
Last Updated: 12 April 2025
Cempakamy Horoshop ("the Studio", "we", "us") is committed to handling your personal information carefully and transparently. This policy explains what we collect, how we use it, and what rights you have regarding your data. It applies to information collected through this website and through the studio's intake and service processes.
For questions about this policy, contact us at [email protected].
1. What We Collect
We collect personal information you provide directly to us, including:
- Contact details — name, email address, and phone number submitted via our enquiry form or provided during service intake.
- Watch information — reference details, serial numbers (where visible), and condition notes relevant to the service requested.
- Correspondence — the content of any emails or messages you send to the studio.
- Usage data — if you have accepted analytics cookies, we may collect anonymised information about how you interact with this website (pages visited, time spent).
Legal basis: We process your data under legitimate interest (responding to enquiries), contractual necessity (carrying out agreed services), and consent (for analytics cookies). Watch reference and serial data is collected as part of our service documentation obligations.
Retention: Contact and service records are retained for up to 5 years after the last service, to support warranty queries and ownership history. Analytics data is retained in anonymised form only.
2. How We Use Your Information
- Service delivery — to carry out watch repair and restoration services you have requested and to communicate about your piece's status.
- Enquiry response — to reply to questions submitted via the website or by telephone.
- Service records — to maintain intake and work documentation as part of our studio protocols.
- Website analytics — only if you have accepted analytics cookies, to understand how visitors use this site and improve it accordingly.
We do not use your contact information for marketing purposes without your explicit agreement. We do not sell or share personal data with third parties for commercial purposes.
3. Data Sharing
We may share limited personal information with the following categories of third party, strictly as needed:
- Courier services — for the Drop-Off and Collection Programme, your name and delivery address are shared with the insured courier provider to arrange collection and return.
- Website hosting and analytics providers — anonymised usage data may be processed by analytics tools (e.g. Google Analytics) if you have consented to analytics cookies. These providers are bound by their own data processing terms.
- Legal compliance — we may disclose information if required to do so by Malaysian law or a competent authority.
We do not transfer personal data outside Malaysia except as necessary for internationally-operated courier services, in which case appropriate safeguards apply.
4. Data Protection Measures
- This website is served over HTTPS. Data in transit between your browser and the site is encrypted.
- Service records containing watch details and owner information are held in access-controlled systems accessible only to studio staff directly involved in your service.
- Physical intake documentation is stored securely at the studio premises.
- In the event of a data breach affecting your personal information, we will notify you and the relevant authority as required under the Personal Data Protection Act 2010 (PDPA) of Malaysia.
5. Cookies
We use cookies on this site. Essential cookies are always active and support basic site functionality. You may accept or decline optional cookies (analytics, marketing, preferences) when the cookie notice appears on your first visit.
For full details on the cookies we use, see our Cookie Policy.
6. Your Rights
Under the Personal Data Protection Act 2010 (Malaysia), you have the following rights regarding your personal data held by the studio:
- Right of access — you may request a copy of the personal data we hold about you.
- Right of correction — you may request that inaccurate data be corrected.
- Right to withdraw consent — where processing is based on your consent (e.g. analytics cookies), you may withdraw consent at any time without affecting prior processing.
- Right to prevent processing — you may object to processing of your data for certain purposes, including direct marketing.
- Right to erasure — you may request deletion of your data where we no longer have a legal basis to retain it.
To exercise any of these rights, contact us at [email protected]. We will respond within 21 days.
You may also raise concerns with the Personal Data Protection Commissioner of Malaysia, the supervisory authority for data protection in Malaysia.
7. Third-Party Links
This website may contain links to external sites — for example, courier provider information or payment-related pages. We are not responsible for the privacy practices of those sites and encourage you to review their policies independently.
8. Children's Privacy
Our services are intended for adults. We do not knowingly collect personal data from individuals under 18 years of age. If you believe a minor has submitted data to us, please contact us at [email protected] so we can remove it.
9. Policy Updates
We may update this policy from time to time. Changes will be posted on this page with a revised "Last Updated" date. We encourage you to review this page periodically. Continued use of the website after a policy update constitutes acceptance of the revised terms.
10. Contact the Data Controller
Cempakamy Horoshop
47 Persiaran Gurney, 10250 George Town, Pulau Pinang, Malaysia